What You Should Know
	Research Education Series
	January 29, 2003

	Not based on outcome, but on situation
	No distinction between “actual” and “potential”
	Not misconduct, per se

	Current USC Policy evolved over a five year period in response to Federal regulatory policy (1990-95)
		Public Health Service (PHS) – Objectivity in Research
		National Science Foundation (NSF) – Financial Disclosure Policy
		Final Rule Issued – July 11, 1995

	Maintain an appropriate written and enforced policy on conflict of interest (complies with federal requirements and inform investigators of the policy)
	Designate an institutional official(s) to solicit and review financial disclosure statements from each investigator planning to participate in research
	Require that investigators submit disclosure of financial interests prior to submission of application for funding

	Required for all NSF and PHS funding applications
	Applies to those involved with the design, conduct, or reporting of research
	Related financial interests must be disclosed

	“Financial Interest”
		Income > $10,000 (salary, fees, honoraria, dividends)
		Equity > $10,000 or a 5% ownership interest
		Intellectual property interest on a patent, patent application, or copyright of software assigned to a party other than USC

	“Financial Interest” related to a sponsored project
		Will manufacture or commercialize a product that will predictably result from the project
		Results would be relevant to the development, manufacture, or improvement of a product
		Income from consulting > $10,000
		Result in subcontract, lease of property or procurement
		Referral of participants or collaborations

	Provides overall framework for unit policies
	Each unit having separate tenure and promotion criteria  required to have a policy
	Review of unit policies by the USC Conflict of  Interest Committee
	Last of 43 unit policies approved (July 1995)

	Faculty will seek prior administrative approval of outside professional activities, and will report these activities annually

	Faculty – all administrators holding academic appointments and all professors, associate professors, assistant professors, full-time academic instructors and full-time lecturers who are not degree candidates
	Financial Interest – any monetary interest which could be construed as having a potential impact on University-related work
	Immediate Family – an individuals spouse, children, parents, and/or other members of the individuals household

	Compensated services
		Contract with any private sector entity
		Ownership or equity in a business or corporation
		Management or board position in a business or corporation
		Participation in a contract or proposal through an entity other than the University

		Participation in service or teaching contract with another college or university
		Academic remuneration noted as fees or honoraria
	Unpaid consulting or pro bono service

	Activities not normally reported
		Colloquia
		Textbooks
		Paintings
		Performances

	Type of activity
	Whether the activity is compensated
	Duration/time requirements
	Explanation of any potential conflict of interest or commitment
	Whether the activity involves the use of University facilities, resources, personnel (including students) or other commitment and whether appropriate procedures have been followed

	Determination of conflict of interests or financial conflict
	Recommendations to prevent or reduce conflicts to a manageable level
			Required public disclosure
			Monitoring by independent reviewers
			Modification of research plan
			Disqualification from participation in research
			Divestiture of significant financial interests
			Severance of relationships that create conflicts